The following are organizing, investigating, and information summarizing Documents I have made or modified for my use. I attempted to remove my information for most so you can print and go.
When I first became a Steward in a large facility (400+ Compliment) I found two issues:
- Even the best case files lacked efficient organization or a heads or tales of what was exchanged, if deadlines were met, etc.
- A lack of using organizational tools as evidence to win Grievances.
To expound, several times I found that by clearly indicating something was an original, or categorizing what was exchanged during Step 2, can create or affirm violations of our Collective Bargaining Agreement. Since seeing these errors I created or modified organizational tools to strengthen Grievances.
Please Modify EVERYTHING for your personal use.
Documents:
This first document is a Class Action Chronology. I use this as both a Chronology and a piece of evidence to prove timeliness. In Class Action Grievances Management often disputes timelines. I have found that the more times you emphasize the timeline the less likely Management is to challenge it.
This is a Non – Moving Document List. For Grievances you do not appeal to Step 3 / Arbitration yourself (Such as a Steward whose local only has them handle Step 2’s) or when sending documents to an NBA, I find it pertenant to list what is Moving and what is NOT Moving.
It is important to note that the whole file could be exchanged if subpoenaed. Never send anything to an NBA that would ruin your case or place liability on your Local / the APWU.
This modified form was born in an office where I often had disputes over the timeliness of Discipline. The Grievance meetings were scheduled in person and over the phone, and at times, disputes would arise.
This document is also used to affirm violations of the difference between a pre-disciplinary and investigatory interview and confirm violations management makes in their timelines.
When the office I am representing has an issue or dispute over Requests for Information being handled in an untimely manner, I include RFI dates of sent and received.
I was provided this when I began handling my own Step 2’s years ago. My frequency of using it has waned as I do most things electronically, but it is extremely useful to have a dated document when you submit anything to Management.
This is my ‘Seven Test’ worksheet. When I first became a Steward, I would write the original 7 Tests and the notes of each test in a notepad. While I investigated, I would fill in any violations or if management met the test. Over time, this became automatic.
Over the years, I have met many Stewards who did not know the original 7 Tests and did not have a format on how to ‘do the math’, so to speak. I added the text on pages 8 and 9 and began sharing this after getting the same questions over and over.
When I use this myself, I remove pages 8 and 9 and write out each violation on each page. In my Step 2 Appeal, I raise the Contention that Management’s discipline is not for Cause and cite this as an Exhibit to prove this fact.
This is my Regular Attendance Math template I have used since 2019. When Management claims an employee is ‘irregular in attendance.’ I use this in conjunction with Interviews to confirm Management never expressed a clear definition of ‘Regular’ with the Grievant, and that the Supervisor themselves does not have a clear definition of the ELM provision.
This worksheet makes it extremely easy to argue that management is being punitive. As long as the Grievant comes to work 80% of the time, this bolsters the ‘Reasonable Person’ argument for notification of the rules for Just Cause.
NOTE: Some of the ‘Math’ is incorrect, as I have modified this form several times. You must replace all information with your case, so I never corrected the numbers in each section.
APWU Steward 